Since Parliament passed the LETA (Act on the Transparency of Legal Entities and the Identification of Beneficial Owners) and amended the AMLA on 26 September 2025, the key question was no longer whether, but when, the new transparency regulations would take effect. That question has now been officially answered. With its decision of 12 June 2026, the Federal Council gave the go-ahead and thereby also triggered the transition periods.
1. Effective Date Confirmed: 1 October 2026
At its meeting on 12 June 2026, the Federal Council decided that the new Act on the Transparency of Legal Entities (LETA) will take effect on 1 October 2026. This officially confirms the timeline referred to as “planned” in the original article. For companies and consultants, this date marks the actual starting point: As of 1 October 2026, the statutory transition periods for registration in the new transparency register will begin.
2. Exception for Public Notaries: Need for Cantonal Regulations Delays Implementation
An important clarification regarding the original article we published on our KYC blog: The provisions concerning public notaries will not be introduced at the same time. The Federal Council has postponed their implementation to give the cantons the necessary time to adapt their own legislation. This applies exclusively to notaries employed under public law. Freelance notaries and attorneys who perform structuring activities, on the other hand, will remain fully subject to the Anti-Money Laundering Act (AMLA) as of 1 October 2026. For affected law firms, it is recommended to establish a clear internal distinction, both in terms of client classification and documentation.
3. Registration Deadlines: Specific Deadlines Instead of Open Time Frames
With the confirmation of the date of 1 October 2026, these deadlines (pursuant to Art. 51 and 53 LETA) can now be broken down into specific calendar dates:
|
Type of Society
|
Deadline for Initial Registration
|
|
Corporations subject to regular auditing requirements
|
1 January 2027
|
|
Other companies subject to mandatory audits
|
1 February 2027
|
|
Corporations Not Subject to mandatory audits
|
1 March 2027
|
|
Foreign legal entities that are in scope as per the law
- Registration with the Transparency Register (Art. 9(4) LETA)
- Appointment of a Representative (Art. 17 LETA, Art. 53 LETA)
|
1 November 2027
1 April 2027
|
|
Companies whose beneficial owners are already registered in the commercial register
|
1 October 2028
|
Foreign legal entities must also designate a representative or provide a registered address in Switzerland (Art. 17 LETA). Special caution is also required for companies governed by Swiss private law that make any changes to the Commercial Register after 1 October 2026: In this case, the reporting deadline is reduced to one month. This applies regardless of the otherwise applicable transition period (Art. 51(1) LETA).
Pursuant to Article 19 of the LETA, the Federal Council may establish simplified identification and verification rules or a simplified reporting procedure for certain types of legal entities that pose limited risks.
4. Transparency Registry: Pilot Program Already Underway
The Federal Office of Justice has launched a pilot program for the transparency registry. The registry can be accessed at www.transpareg.admin.ch. Reports must be submitted exclusively through EasyGov - pre-registration is already available. The pilot program is voluntary and free of charge and will run until the LETA takes effect, but for no longer than two years. The data can be imported directly into the Transparency Register - thereby fulfilling the company’s reporting obligation.
What should we do now?
Companies should begin documenting their full ownership and control structure today, identify beneficial owners in accordance with Articles 7 and 8 of the LETA, obtain supporting documentation, and establish an internal reporting process for changes. Commercial register entries for companies governed by Swiss private law made after 1 October 2026, trigger a 30-day reporting deadline.
Financial intermediaries must integrate the transparency register into their KYC processes as a supplementary verification source and establish an internal process to comply with the 30-day reporting requirement for discrepancies in the register as defined by law.
The easiest way to comply with Articles 7 and 8 of the LETA is to follow a clear process: identify, verify, document. That’s exactly what our KYC Spider Toolbox offers - with commercial register cross-checking and online identification for verifying documents, and KYC Files for centralized, traceable documentation of your ownership structure. For further information or if you have any questions, please feel free to contact support@kyc.ch.
This article is intended solely for general informational purposes and does not constitute legal or compliance advice. It will not be updated and reflects our understanding as of the end of June 2026.